Home > Privacy & Security
Back to previous page

Welcome to TimeLine Auctions Limited's privacy policy.

TimeLine Auctions Limited is a company incorporated in England and Wales with registered number 06873501 whose registered office is at 40 Kilmarnock Drive, Luton, LU2 7YP (collectively referred to as TimeLine, "we", "us" or "our" in this privacy policy).

TimeLine respects your privacy and is committed to protecting your personal data and takes the privacy of your information very seriously. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy applies between you, the user of our website, and TimeLine, the owner and provider of this website.

This privacy policy includes our cookies policy.

  1. Important information and who we are

Purpose of this privacy policy

This privacy policy aims to give you information on how TimeLine collects and processes your personal data through your use of this website, including any data you may provide through this website when for example you register to bid in an auction or subscribe to our catalogues or sign up to our newsletter.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

Controller

TimeLine is the controller and responsible for your personal data.

We have appointed a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.

Contact details

If you have any questions about this privacy policy or our privacy practices, please contact our data privacy manager in the following ways:

Name: Damir Radic

Email address: marketing@timelineauctions.com

Postal address: 363 Main Road, Harwich, Essex, CO13 4DN

Telephone number: 01277 815121

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy and your duty to inform us of changes

We keep our privacy policy under regular review. This version was last updated in October 2020.

It is important that the personal data we hold about you is accurate and current. Please keep us informed by email if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  1. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

  • Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
  • Contact Data includes billing address, delivery address, email address and telephone numbers.
  • Financial Data includes bank account and payment card details.
  • Transaction Data includes details about payments to and from you and other details of products you have purchased from us.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

  1. How is your personal data collected?

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us your personal data by filling in forms or by corresponding with us by post, phone, email or otherwise or when meeting face to face. This includes personal data you provide when you:
  • register to bid in an auction;
  • create an account on our website;
  • agree to sell your property through TimeLine or ask us to perform a valuation;
  • express an interest in buying or selling certain types of property to one of our staff or representatives;
  • subscribe to our catalogues;
  • sign up on timelineauctions.com to receive news about upcoming auctions and events relating to particular areas of interest;
  • attend one of our events; or
  • give us feedback or contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy set out under heading 10 below for further details.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
  • Businesses which we have contracts to provide services as part of our business operations, including:

(a) payment service providers such as SagePay;

(b) shipping, delivery and courier companies such as MBE;

(c) Third party bidding platforms.

  • Technical Data from the following parties:

(a) analytics providers such as Google based outside the EU;

(b) search information providers such as Google based outside the EU.

(c) Contact, Financial and Transaction Data from providers of technical, payment and delivery services such as SagePay based inside the EU.

(d) Identity and Contact Data from publicly available sources such as Companies House, Electoral Register and Art Loss Register based inside the EU.

  1. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will obtain your consent before sending third party direct marketing communications to you via email or text message or in circumstances where the relevant action is not within any other legal basis on which we may rely.

You have the right to refuse or withdraw consent to marketing or any other activity at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

(a) To register you as a new customer

(b) To meet proof of identity requirements

(a) Identity

(b) Contact

(a) Performance of a contract with you

(b) Comply with legal obligations

To register your bid including:

(a) Checking your credit score

(b) Manage payments, fees and charges

(b) Collect and recover money owed to us

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

To provide services to you including:

(a) Arranging delivery and shipping of auctioned goods to client

(b) Circulating promotional material and catalogues

(a) Identity

(b) Contact

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (performance of a contract)

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To enable you to complete a survey

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to study how customers use our services, to develop them and grow our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To comply with our legal and regulatory duties and obligations including:

(a) Government departments (e.g. Arts Council; HM Revenue and Customs)

(b) Anti-money laundering compliance

(c) Provenance checking services (e.g. Art Loss Register)

(a) Identity

(b) Contact

(c) Profile

(a) Necessary for our legitimate interests (performance of contracts)

(b) Legal obligations

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by emailing us (marketing@timelineauctions.com) or ‘clicking’ unsubscribe within electronic marketing or promotional material where applicable.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration or other transactions.

Where you request to opt out of promotional and marketing messages you may continue to receive communications for a short period while we process your request and our systems are updated.

Cookies and Cookies policy

Our website uses a number of cookies. A cookie is a small file of letters and numbers that we put on your computer if you agree. These cookies allow us to distinguish you from other users of our website, which helps us to provide you with a good experience when you browse our website and also allows us to improve our site. We have carefully chosen these cookies and have taken steps to ensure that your privacy is protected and respected at all times.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
  • Analytical or performance cookies. These allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
  • Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

You can choose to enable or disable cookies in your internet browser. By default, most internet browsers accept cookies but this can be changed. For further details, please consult the help menu in your internet browser.

You can choose to delete cookies at any time; however you may lose any information that enables you to access our website more quickly and efficiently including, but not limited to, personalisation settings and may not be able to access all or parts of our website.

We do not use cookies to gather information from you other than information about our own website.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us by email at marketing@timelineauctions.com.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

  1. Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table Purposes for which we will use your personal data above under heading 4.

  • Other companies within our group.
  • We will only transfer your personal data to other organisations where it is necessary to enable us to provide you with the services you have requested (for example: we may transfer your data to our bank, payment card acquirers, shippers, warehouses, insurers, experts who help us authenticate or value property, event venues, catalogue and direct marketing fulfilment and distribution).
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
  • Other businesses (such as other auction houses) for the purpose of obtaining references and information verification.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

  1. International transfers

Some of the external third parties we transfer personal data are based outside the EEA and their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to your personal data as it would have if it were to be kept within the EEA by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

  1. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. Data retention

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances you can ask us to delete your data, see heading 9 Your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Your legal rights

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data. This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
  • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
  • If you want us to establish the data's accuracy.
  • Where our use of the data is unlawful but you do not want us to erase it.
  • Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
  • You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us by email at marketing@timelineauctions.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

If a password is required for using certain parts of our website, you are responsible for keeping this password confidential.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

General

If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.

This privacy policy is governed by and interpreted according to the law of England and Wales. All disputes arising under it will be subject to the exclusive jurisdiction of the English and Welsh courts.

 

 

Welcome to TimeLine Auctions Limited's Anti-Money Laundering Policy (“AML Policy”).

TimeLine Auctions Limited is a company incorporated in England and Wales with registered number06873501whose registered office is at 40 Kilmarnock Drive, Luton, LU2 7YP(collectively referred to as “TimeLine”, "we", "us" or "our" in this AML Policy).

TimeLine understands that the art market is particularly susceptible to money laundering and takes anti-money laundering very seriously. This AML Policy will inform you as to the legal framework and which information we will require from you in order to adequately identify you.

This AML Policy applies to you in case you want to deal with us.

If you have questions or would like further information please contact TimeLine’s AML Compliance team at: enquiries@timelineauctions.com or TimeLine’s AML Reporting Officer at: admin@timelineauctions.com.

  1. PURPOSE OF THIS AML POLICY

This AML Policy sets out how TimeLine will achieve compliance with its legal and regulatory obligations under the anti-money laundering regimes.

All employees are tasked with enforcing TimeLine’s AML Policy. Ongoing training will be provided to train and equip TimeLine’s employees with the knowledge of their anti-money laundering responsibilities. Where grounds to suspect money laundering are discovered, TimeLine’s employees will be encouraged to report any suspicions to the National Crime Agency.

All customers (namely sellers and bidders) of Timeline must familiarise themselves and comply with this AML Policy.

  1. LEGAL FRAMEWORK

Under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 ("2017 Regulations"), as amended and extended by the Money Laundering and Terrorist Financing (Amendment) Regulations 2019 allauctioneers are required to verify the identity of all customers before auction. Any auction house or art dealer who meets the definition of a “high value dealer” is obliged to put policies, procedures and training into force. All of the above are to be based on a risk assessment, to ensure all customer identities are checked and capable of being verified.

All of our risk assessments will consider the following factors: customer, geographic, products, transactions and delivery channels.

In addition, the European Fifth Money Laundering Directive (“Fifth Directive”) was implemented in the United Kingdom in January 2020 and extends the definition of “obligated entities” to “persons trading or acting as intermediaries in the trade of works of art, including when this is carried out by art galleries and auction houses, where the value of the transaction or a series of linked transactions amounts to EUR 10 000 or more”.

Pursuant to the requirements of the Fifth Directive, transactions relating to cultural artefacts and other items of archaeological, historical, cultural and religious importance, or of rare scientific value, as well as ivory and protected species will be subject to enhanced due diligence undertaken by TimeLine.

  1. CUSTOMER DUE DILIGENCE

When entering into a transaction with TimeLine, all customers are subject to customer due diligence conducted by us, in order to identify each and every customer.

Such due diligence will require customer participation and will include an evaluation as to the background and purpose of all such transactions. We would recommend that as much information in relation to any of the items of the transaction be prepared and made accessible to us as soon as possible, to avoid time delays.

In relation to corporate structures, we strongly advise you to prepare the necessary paperwork in advanceof engaging Timeline to minimise the time taken to conduct our due diligence. We may have to examine each layer of the structure until we have identified the ultimate beneficial owner(s). If we are not fully satisfied, we will not be able to proceed with the transaction.

We will require the following documentation for the following people/entities:

UK Private Individuals

All UK private individuals must provide one document from each list.

List A: Identity documents:

  • Current signed passport;
  • Original birth certificate; or
  • Current UK photo card driving licence.

If you do not currently hold a valid passport or driving licence, you may provide a certified copy(see below requirements for certified copies) of one of the following documents:

  • EEA member state identity card;
  • UK old style paper driving licence;
  • Residence permit issued by the Home Office to EEA Nationals on sight of their own country passport;
  • Benefit book or original notification letter from the Benefits Agency confirming the right to benefits;
  • Self-employed in the construction industry – tax exemption certificate with photograph of holder (forms C155, C156 or SC60);
  • HM Revenue and Customs tax notification;
  • National identity card bearing a photograph of the applicant; or
  • Firearms or shotgun certificate.

List B: Evidence of address

  • A utility bill issued within the last three months (but not mobile phone bills as these can be sent to different addresses);
  • Current UK driving licence (if not used as evidence of identity);
  • UK old style paper driving licence (if not used as evidence of identity);
  • Local authority council tax bill (valid for the current year);
  • Bank, Building Society or Credit Union statement issued within the last three months and addressed to the current residential address;
  • Original mortgage statement from a recognised lender issued for the last full year;
  • Electoral Register entry;
  • Benefit book or original notification letter from the Benefits Agency confirming the right to benefits (if not used as evidence of identity);
  • Self-employed in the construction industry – tax exemption certificate (forms C155, C156 or SC60) (if not used as evidence of identity);
  • NHS Medical card or letter of confirmation from GP’s practice of registration with the surgery; or
  • HMRC self-assessment letters or tax demand dated within the current financial year.

We do not accept the following as evidence of address:

  • Provisional driving licence.
  • Mobile phone bills.
  • Credit card statements.
  • PO Box numbers.
  • Addresses listed as ‘C/O’.
  • Online bank statements.
  • Online utility bills.
  • Health insurance certificates.
  • Building contents insurance certificates.
  • Motor insurance certificates.

Non-UK Private Individuals

All non-UK individuals must confirm whether they are a person established in a high risk country or a ‘Politically Exposed Person’. To satisfy the requirements of the 2017 Regulations we may have to apply enhanced due diligence measuresand you will be informed if such enhanced measures are applicable to you.

All non-UK private individuals must provide one document from each list.

List A: Identity documents:

  • Full and valid passport;
  • A EU or EEA National identity card; or
  • Photo driving licence.

List B: Evidence of address:

  • A utility bill issued within the last three months (but not mobile phone bills as these can be sent to different addresses);
  • Bank, Building Society or Credit Union statement issued within the last three months and containing a current address; or
  • A reference from a bank or regulated legal professional who has advised the individual for at least the past two years.

Certified copies (see below requirements for certified copies under Certification of Documentation) of the above documents are also acceptable.

We do not accept the following as evidence of address:

  • Provisional driving licence.
  • Mobile phone bills.
  • Credit card statements.
  • PO Box numbers.
  • Addresses listed as ‘C/O’.
  • Online bank statements.
  • Online utility bills.
  • Health insurance certificates.
  • Building contents insurance certificates.
  • Motor insurance certificates.

Corporate Bodies, including Trusts and other legal entities

We will not be able to proceed with a transaction from a corporate body until we are fully satisfied that we have identified the ultimate beneficial owner(s).

Please note thatPart 5 of the 2017 Regulations (section 43(1)) places a legal duty on all corporate bodies(including trusts and other legal entities) to provide us with information identifying the following:

  • name, registered number, registered office, principal place of business and nature of business;
  • board of directors and all other individuals who exercise management control, or if there is no board, the members of the equivalent management body;
  • senior persons responsible for its operations;
  • law to which it is subject;
  • copy of certificate of incorporation (where applicable);
  • legal owner(s) and all individuals or entities with 25% or more of the shareholding, or capital, or profit, or trust property, or voting rights;
  • copy of filed audited accounts;
  • beneficial owner(s); and
  • articles of association and other governing documents.

Regular updates as to proof of registration for legal entities will be required.

For full details of the requirements in relation to corporate structures, you can request a copy of our AML Corporate Information Request - Corporate and Trust.

Intermediaries

We will also require identity verification and undertake customer due diligence of any intermediary making a purchase on the behalf of another.

Certification of Documentation

Documents must be professionally certified by an independent certifier, who has had sight of the original documents, and the date of certification, signature, name, company, position and telephone number of the certifier must be provided.

Documents may be certified by:

In the UK:

  • A credit or financial institution which is an authorised person *FCA regulated entity/individual; or
  • An auditor, insolvency practitioner, external accountant, tax advisor, or independent legal professional that is supervised by one of the following bodies:
    • Association of Chartered Certified Accountants *Chartered accountant.
    • Council for Licenced Conveyancers *Specialist property & probate lawyer.
    • Faculty of Advocates *Lawyer.
    • General Council of the Bar *Barrister.
    • General Council of the Bar of Northern Ireland *Barrister.
    • Institute of Chartered Accountants in England and Wales *Chartered accountant.
    • Institute of Chartered Accountants in Ireland *Chartered accountant.
    • Institute of Chartered Accountants in Scotland *Chartered accountant.
    • Law Society *Solicitor.
    • Law Society of Scotland *Solicitor.
    • Law Society of Northern Ireland *Solicitor.

In addition to the above, the following may also certify UK national private individual documentation provided the independent certifier is also located in the UK.A professional person must certify your document or someone well respected in your community (‘of good standing’). You could ask the following if they offer this service:

  • Bank or Building Society Official.
  • Councilor.
  • Minister of Religion.
  • Dentist.
  • Chartered Accountant.
  • Solicitor or Notary.
  • Teacher or Lecturer.

However, the person you ask should not be: related to you, living at the same address or in a relationship with you.

Non-UK:

  • An authorised representative of an Embassy or Consulate of the county who issued the identification document;
  • A registered notary public, justice of the peace, lawyer or advocate;
  • An accountant who is a member of an accounting professional institution; or
  • A credit or financial institution who is regulated and supervised for compliance with the requirements laid down in the money laundering directive.

Acceptable Certified Wording

Please ensure the following wording is used verbatim:

  • For evidence of identity
    "I certify that this is a true copy of the original document which has been seen. The photograph bears a true likeness of the individual."
  • For evidence of address
    "I certify that this is a true copy of the original document which has been seen." [date, signature, name, company, position and date]